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Back to the future: attribution of futures contract gains under Australia's CFC regime

Published on 01 Apr 06 by "THE TAX SPECIALIST" JOURNAL ARTICLE

Australia’s Controlled Foreign Company (“CFC”) rules have been the subject of several major reforms in recent years. The reforms have changed the scope of these rules, however, the CFC rules continue to be a significant risk area for taxpayers engaging in international transactions. This paper will focus on one particular type of transaction, namely the potential attribution under the CFC rules of gains made in respect of forward and futures contracts.

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Philip BENDER

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